new york state department of environmental conservation ...permit id: 4-0124-00001/00112 renewal...

Division of Air Resources Permit Review Report

Permit ID: 4-0124-00001/00112Renewal Number: 1

Modification Number: 20 10/07/2020

Facility Identification DataName: LAFARGE BUILDING MATERIALS INCAddress: 1916 US RTE 9WRAVENA, NY 12143-0003

Owner/FirmName: HOLCIM (US) INCAddress: 8700 W Bryn Mawr Ave Ste 300Chicago, IL 60631, USAOwner Classification: Corporation/Partnership

Permit ContactsDivision of Environmental Permits:Name: Nancy M BakerAddress: NYSDEC - REGION 41130 N WESTCOTT RDSCHENECTADY, NY 12306-2014Phone:5183572069

Division of Air Resources:Name: GARY MCPHERSONAddress: NYSDEC - REGION 41130 N WESTCOTT RDSCHENECTADY, NY 12306-2014Phone:5183572278

Air Permitting Contact:Name: KATHERINE KESLICKAddress: LAFARGE BUILDING MATERIALS INC1916 US RTE 9W PO BOX 3RAVENA, NY 12143Phone:5187565026

Permit Description IntroductionThe Title V operating air permit is intended to be a document containing only enforceable terms andconditions as well as any additional information, such as the identification of emission units, emissionpoints, emission sources and processes, that makes the terms meaningful. 40 CFR Part 70.7(a)(5) requiresthat each Title V permit have an accompanying "...statement that sets forth the legal and factual basis forthe draft permit conditions". The purpose for this permit review report is to satisfy the above requirementby providing pertinent details regarding the permit/application data and permit conditions in a more easilyunderstandable format. This report will also include background narrative and explanations of regulatorydecisions made by the reviewer. It should be emphasized that this permit review report, while based oninformation contained in the permit, is a separate document and is not itself an enforceable term andcondition of the permit.

Summary Description of Proposed Project

The New Source Performance Standards Subpart F and National1.Emission Standards for Hazardous Air Pollutants Subpart LLL that

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were modified by EPA on February 12, 2013 are updated in theproposed permit. All Subpart LLL standards for existing kilnspreviously applicable on September 9, 2013 have been postponed twoyears to September 9, 2015. The particulate standards and thecompliance method for existing and new kilns and clinker coolerswere changed. A new kiln that had a 30 day rolling average of 0.01pounds of particulate per ton of clinker with compliance demonstratedusing a continuous emissions monitor was changed to an upper limitof 0.02 pounds of particulate per ton of clinker demonstrated withannual stack test. The continuous monitor will still be required, but itwill serve as an indicator of compliance level. Startup and shutdownemission limits have been repealed and replaced with a generalrequirement to operate pollution controls and start up the kilns ondistillate oil or other clean fuel.At Lafarge’s request, the Lafarge Federal Consent Decree was2.amended to extend the deadline for construction of the new Kiln #3 toJuly 1, 2016. To make this extension emission neutral, new caps fornitrogen dioxide and sulfur dioxide emissions from the existing kilnswere adopted to reflect the lower emission rates that would haveoccurred if the new Kiln #3 had commenced operation in January2015. For NOx, a 10,650 ton cap was added for the operation fromJanuary 1, 2013 through June 30, 2016. For SO2, two new caps wereadded. A new 12 month rolling limit of 7,000 tons replaces theexisting 11,500 ton limit. A new 19,385 ton cap applies for the periodfrom January 1, 2013 through June 30, 2016. All NOx and SO2

emissions are calculated using continuous emission monitors.To make the extended deadline for construction of the new Kiln #33.emission neutral for mercury, new caps for annual emissions and acap for emissions for the January 2013 through June 2016 period areproposed for the existing kilns on the state side of the permit. Theexisting 12 month rolling limit of 176 pounds will be reduced to 132

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pounds. A new cap of 354 pounds will apply for the period fromJanuary 1, 2013 through June 30, 2016. The existing methods ofsampling and analysis of kiln feed slurry, coal and coke, and cementkiln dust will be used to demonstrate compliance with these new caps.Lafarge has requested and the Department proposes to grant an4.extension of the September 9, 2015 NESHAP Subpart LLLcompliance deadlines to June 30, 2016 based on the language in 40CFR 63.6(i). This extension will allow the existing kilns and clinkercoolers to operate in compliance with Federal regulations until thenew Kiln #3 and clinker cooler is scheduled to begin operation. Thisproposed condition requires Lafarge to comply with the FederalConsent Decree construction milestones which are incorporated in thecondition and report construction progress on 6 interim dates.Reasonably available control technology for nitrogen oxides has been5.updated for the existing kilns. Compliance with a new limit of 5.2pounds of NOx per ton of clinker for each 30 day period is possibleusing the selective noncatalytic reduction system (SNCR) that wasinstalled on existing Kiln #2. Operation of Kiln #1 is not prohibitedin the permit, but the SNCR system has not been installed on Kiln #1at this time.Lafarge has requested that existing fuel sampling Conditions 12-11,6.12-12, and 12-13 be removed from the Title V permit. Lafarge wouldlike to terminate the daily coal sampling and analysis which is used tocomply with these Subpart 225-1sulfur in fuel standards and insteadcalculate compliance with the equivalent emission rates using theirsulfur dioxide continuous emission monitoring system. Thisequivalent emission rate is allowed under Condition 12-80, and theapplicable Subdivision 220-1.6(a) was reapproved by theEnvironmental Protection Agency on July 12, 2013.

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Attainment StatusLAFARGE BUILDING MATERIALS INC is located in the town of COEYMANS in the county ofALBANY.The attainment status for this location is provided below. (Areas classified as attainment are those thatmeet all ambient air quality standards for a designated criteria air pollutant.)

Criteria Pollutant Attainment Status------------------------------------------------------------------------------------------------------------------------------------Particulate Matter (PM) ATTAINMENT

Particulate Matter< 10µ in diameter (PM10) ATTAINMENT

Sulfur Dioxide (SO2) ATTAINMENT

Ozone* MARGINAL NON-ATTAINMENT

Oxides of Nitrogen (NOx)** ATTAINMENT

Carbon Monoxide (CO) ATTAINMENT

------------------------------------------------------------------------------------------------------------------------------------

* Ozone is regulated in terms of the emissions of volatile organic compounds (VOC) and/or oxides ofnitrogen (NOx) which are ozone precursors.** NOx has a separate ambient air quality standard in addition to being an ozone precursor.

Facility Description:Cement manufacturing facility currently operating under Title V permit.

Permit Structure and Description of OperationsThe Title V permit for LAFARGE BUILDING MATERIALS INC is structured in terms of the following hierarchy: facility, emission unit, emission point, emission sourceand process. A facility is defined as all emission sources located at one or more adjacent or contiguousproperties owned or operated by the same person or persons under common control. The facility issubdivided into one or more emission units (EU). Emission units are defined as any part or activity of astationary facility that emits or has the potential to emit any federal or state regulated air pollutant. Anemission unit is represented as a grouping of processes (defined as any activity involving one or moreemission sources (ES) that emits or has the potential to emit any federal or state regulated air pollutant).An emission source is defined as any apparatus, contrivance or machine capable of causing emissions ofany air contaminant to the outdoor atmosphere, including any appurtenant exhaust system or air cleaningdevice. [NOTE: Indirect sources of air contamination as defined in 6 NYCRR Part 203 (i.e. parking lots)are excluded from this definition]. The applicant is required to identify the principal piece of equipment(i.e., emission source) that directly results in or controls the emission of federal or state regulated airpollutants from an activity (i.e., process). Emission sources are categorized by the following types:combustion - devices which burn fuel to generate heat, steam or powerincinerator - devices which burn waste material for disposalcontrol - emission control devicesprocess - any device or contrivance which may emit air contaminants that is not included in the above categories.

LAFARGE BUILDING MATERIALS INC is defined by the following emission unit(s):

Emission unit 020000 - THIS UNIT CONSISTS OF EXISTING SOURCES INVOLVED IN THE

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HANDLING OF THE RAW MATERIALS AND SOLID FUELS AT THE FACILITY.

Emission unit 020000 is associated with the following emission points (EP):34301, 46012, 46013, 46014, 46015, 46017Process: FAX is located at ROOF, Building FLYASHSILO - TRANSFER OF FLY ASH TO FLY ASHSTORAGE SILO FROM TRUCKS AND FROM SILO TO FLY ASH ALLEVIATOR.Process: LCR is located at GROUND, Building 2NDCRUSHER -Process: LMS is located at Building MILLBLDING - STORAGE AND TRANSFER OF LIMESTONEFROM THE SILOS TO THE MILLING MACHINES.

Process: MAS is located at Building MASONSILO - TRANSFER OF MATERIAL INTO AND OUT OFTHE MASONARY FRINGE SILO. THIS PROCESS IS VENTED BY A DUST COLLECTORLOCATED ON TOP OF THE MASONARY FRINGE SILO.

Process: RX1 is located at GROUND, Building 2NDCRUSHER - TRANSFER OF RAW MATERIALSTHROUGH THE SECONDARY CRUSHER AND ONTO CONVEYOR #7. CALCIUM SOURCES(LIMESTONE), SOLID FUELS, AND IRON SOURCES ARE TRANSFERRED THROUGH THESECONDARY CRUSHER AND ONLY CONVEYOR #7.Process: RX2 is located at 6, Building MILLBLDING - TRANSFER OF RAW MATERIALS(CALCIUM SOURCES, SOLID FUEL, AND IRON SOURCES) FROM CONVEYOR 7 DISCHARGECHUTE TO THE SHUTTLE BELT LOAD CHUTE.

Emission unit 090000 - EMISSION UNIT 090000 CONTAINS EXISTING EMISSION SOURCESINVOLVED IN THE FACILITY'S QUARRY OPERATIONS. THIS INCLUDES THE PRIMARYCRUSHER LOCATED IN THE PRIMARY CRUSHER BUILDING.

Emission unit 090000 is associated with the following emission points (EP):32002Process: PCR is located at GROUND, Building PRCRUSHER -Process: PCS is located at Building PRCRUSHER -

Emission unit 053000 - THIS UNIT CONSISTS OF EXISTING AND MODIFIED EQUIPMENTASSOCIATED WITH FINISH MILL NO. 3. THIS INCLUDES FEED BELTS TO THE CEMENTMILL, THE MILL, CONVEYING EQUIPMENT AFTER THE MILL (BUCKET ELEVATOR AND AIRSLIDES), THE MILL 3 SEPARATOR AND CEMENT COOLER. COMPONENTS OF THE CEMENTMILL 1 SYSTEM ARE CONTAINED IN THE MILL BUILDING.

Emission unit 053000 is associated with the following emission points (EP):43603, 43604, 52301, 53301, 53302Process: CM3 is located at GROUNDN, Building MILLBLDING -Process: FM3 is located at Building MILLBLDG -Process: FX3 is located at ALL, Building MILLBLDING -

Emission unit 055000 - THIS UNIT CONSISTS OF ALL EQUIPMENT ASSOCIATED WITH NEWFINISH MILL NO. 5 INCLUDING THE ADDITIVE STORAGE AND MILL FEED SYSTEMS.

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Emission unit 055000 is associated with the following emission points (EP):40301, 40302, 40303, 45301, 45302, 45303, 45304, 45606, 46301, 46302, 46303, 46304, 46501Process: FAD is located at Building MILLBLDG -Process: FBF is located at Building FMBINS -Process: FBH is located at Building FM5BH -Process: FM5 is located at Building FM5 -

Emission unit 054000 - EMISSION UNIT 054000 CONSISTS OF THE CEMENT MILL 4 SYSTEM.THIS INCLUDES FEED BELTS TO THE CEMENT MILL, THE MILL, CONVEYING EQUIPMENTAFTER THE MILL (BUCKET ELEVATOR AND AIR SLIDES), THE TWO MILL 4 SEPARATORSAND CEMENT COOLER. ALL OF THE COMPONENTS OF THE CEMENT MILL 4 SYSTEM ARECONTAINED IN THE MILL BUILDING.

Emission unit 054000 is associated with the following emission points (EP):52401, 53401, 53402, 53403Process: CM4 is located at GROUND, Building MILLBLDING -Process: FX4 is located at ALL, Building MILLBLDING -Process: FX5 is located at 6, Building MILLBLDING -

Emission unit 041200 - THIS UNIT CONSISTS OF THE KILN AND BYPASS DUCT SYSTEM ANDASSOCIATED DUST COLLECTORS.

Emission unit 041200 is associated with the following emission points (EP):33402, 33403, 33404, 33405, 33502, 33503, 33506Process: BYP is located at Building BYPASS -Process: CKD is located at Building SCRUBBER -Process: SCB is located at Building SCRUBBER -

Emission unit 033000 - THIS UNIT CONSISTS OF THE NEW RAW MILL AND KILN FEEDSOURCES.

Emission unit 033000 is associated with the following emission points (EP):23605, 23606, 23607, 23801, 23802, 23803, 23805, 33202, 33203, 33204, 33205, 33206, 33207Process: KFP is located at Building PREHEAT -Process: RMB is located at Building BLEND -Process: RMR is located at Building RMCYCLON -Process: RMT is located at Building RAWMILL -

Emission unit 052000 - EMISSION UNIT 052000 CONSISTS OF THE CEMENT MILL 2 SYSTEM.THIS INCLUDES FEED BELTS TO THE CEMENT MILL, THE MILL, CONVEYING EQUIPMENTAFTER THE MILL (BUCKET ELEVATOR AND AIR SLIDES), THE MILL 2 SEPARATOR ANDCEMENT COOLER. ALL OF THE COMPONENTS OF THE C EMENT MILL 2 SYSTEM ARECONTAINED IN THE MILL BUILDING.

Emission unit 052000 is associated with the following emission points (EP):52201, 53201, 53202Process: CM2 is located at GROUND, Building MILLBLDING -

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Process: FX2 is located at ALL, Building MILLBLDING -

Emission unit 051000 - THIS UNIT CONSISTS OF EXISTING AND MODIFIED EQUIPMENTASSOCIATED WITH FINISH MILL NO. 1. THIS INCLUDES FEED BELTS TO THE CEMENTMILL, CONVEYING EQU8IPMENT AFTER THE MILL (BUCKET ELEVATOR AND AIR SLIDES),THE MILL 1 SEPARATOR AND CEMENT COOLER. ALL OF TH E COMPONENTS OF THECEMENT MILL 1 SYSTEM ARE CONTAINED IN THE MILL BUILDING.

Emission unit 051000 is associated with the following emission points (EP):41603, 41604, 52101, 53101, 53102Process: CM1 is located at GROUND, Building MILLBLDING -Process: FM1 is located at Building MILLBLDG -Process: FX1 is located at ALL, Building MILLBLDING -

Emission unit 041100 - THIS UNIT CONSISTS OF THE NEW KILN SYSTEM AND CLINKERCOOLER INCLUDING THE KILN, IN-LINE RAW MILL, PREHEATER/PRECALCINER, COALMILL, ALKALI BYPASS, AND CLINKER COOLER, ALL VENTED THROUGH THE MAIN KILNSTACK.

Emission unit 041100 is associated with the following emission points (EP):33401Process: CCL New clinker cooler.

Process: KLN is located at Building PREHEAT - New kiln, in-line raw mill, bypass and coal mill.

Emission unit 100000 - EMISSION UNIT 100000 CONTAINS EXISTING EMISSION SOURCESINVOLVED IN THE FACILITY'S WHARF OPERATIONS. THIS INCLUDES THE TRANSER OFFINISHED PRODUCT FROM BELT 9 TO BARGES. PARTICULATE EMISSIONS FROM THISTRANSFER IS CONTROLLED BY A BAGHOUSE.

Emission unit 100000 is associated with the following emission points (EP):58001Process: CMB is located at GROUND, Building WHARF AREA -

Emission unit 021000 - THIS UNIT CONSISTS OF NEW RAW MATERIALS AND ADDITIVES,STORAGE EQUIPMENT, INCLUDING A NEW SECONDARY CRUSHER AND SCREEN.

Emission unit 021000 is associated with the following emission points (EP):11501, 13801, 13802, 13803, 23301, 23302, 23303, 23304, 23305, 23306, 23307, 23601, 23602, 23603,23604, 23608Process: ADS is located at Building RAWMAT1 -Process: ADTProcess: CR2 is located at Building NEW2NDCR -Process: LSS is located at Building RAWMAT2 -Process: PBL is located at Building PREBLEND -Process: RMX is located at Building RAWMAT1 -

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Emission unit 072000 - THIS UNIT CONSISTS OF EXISTING COVERED BELT CONVEYORSUSED TO TRANSPORT FINISHED CEMENT BETWEEN THE CUSTOMER AND BUFFER SILOSAND FROM THE SILOS TO THE WHARF AREA FOR BARGE SHIPMENT. IT ALSO INCLUDESTHE BUFFER SILOS. THE BELT THAT TRANSFERS PRODUCT BET WEEN THE CUSTOMERAND BUFFER SILOS IS LOCATED AT THE NORTH END OF THE BUFFER SILOS. THE THREEBELTS WHICH TRANSPORT PRODUCT TO THE WHARF ARE BELTS 8A, 8B, AND 9.PARLTICULATE EMISSIONS FROM ALL TRANSFER POINTS ARE CONTROLLED BYBAGHOUSES.

Emission unit 072000 is associated with the following emission points (EP):55001, 55002, 55003, 55004, 55005, 55006, 57001, 57002, 57003, 62001Process: BS1Process: CMX is located at Building BUFFESILOS -Process: CX5 is located at Building BUFFESILOS -

Emission unit 042000 - THIS UNIT CONSISTS OF EXISTING CLINKER DRAG CONVEYORS,BUCKET ELEVATORS, STORAGE SILOS NOS. 8 AND 11 AND ASSOCIATED DUSTCOLLECTORS. THE DUST SCOOP SYSTEMS CURRENTLY PERMITTED AS PART OF THISUNIT WILL BE REMOVED.

Emission unit 042000 is associated with the following emission points (EP):40100, 43102, 43103, 43104, 43105, 43106, 46008, 46011, 46018, 46019Process: CKD is located at Building FEEDENDBLG -Process: CX1 is located at Building MILLBLDING -Process: CX2 is located at Building DISCHENDBG -Process: PEL is located at Building PUGBLDG -Process: PUG is located at Building PUGBLDG -

Emission unit 043000 - THIS UNIT CONSISTS OF THE NEW CLINKER HANDLING ANDSTORAGE EQUIPMENT AND ASSOCIATED DUST COLLECTORS.

Emission unit 043000 is associated with the following emission points (EP):30903, 32801, 33801, 33901, 33902, 33903, 33904, 33905, 33906, 33907, 33908, 33909, 41101, 41102,41103, 41104, 41105, 41106, 41107, 41108, 41109, 41110, 41111, 41112, 41113, 41114, 41115, 41116,41117, 41118, 41119, 41120, 41121, 41122Process: CLD is located at Building COOLER -Process: CS1 is located at Building CLINK1 -Process: CS2 is located at Building CLINK2 -Process: CSE is located at Building CLINKER -Process: CTFProcess: HTB is located at Building HOTBIN -

Emission unit 071000 - THIS UNIT CONSISTS OF EXISTING CEMENT STORAGE, LOADOUTAND PRODUCT SHIPMENT ACTIVITIES AT THE FACILITY. SPECIFICALLY, THIS INCLUDESTHE CUSTOMER SILOS, NORTH AND SOUTH TRUCK LOADING SPOUTS, THE RAILCARLOADING SPOUTS LOCATED AT THE CUSTOMER SILOS, AND TH E EAST AND WESTBAGGING MACHINES LOCATED IN THE PACKHOUSE AS WELL AS THE REVERSIBLE

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CONVEYORS WHICH TRANSFER PRODUCT TO THESE AREAS. MISCELLANEOUS EMISSIONSOURCES ASSOCIATED WITH THE PACKHOUSE (BAG SHREDDER AND VACUUM) AREALSO INCLUDED IN EU 071000.

Emission unit 071000 is associated with the following emission points (EP):62002, 62003, 62004, 62005, 62006, 62007, 62008, 62009, 63001, 63002, 63003, 63004Process: BAG is located at Building PACKHSEBLG -Process: CL1 is located at Building CUSTOSILOS -Process: CL2 is located at Building CUSTOSILOS -Process: CL3Process: CS1Process: CX4 is located at Building CUSTOSILOS -Process: PBS is located at GROUND, Building PACKHSEBLG -Process: PVC is located at GROUND, Building PACKHSEBLG -

Emission unit 071100 - THIS UNIT CONSISTS OF THE NEW CEMENT TRANSFER SYSTEM.

Emission unit 071100 is associated with the following emission points (EP):40801Process: CMT is located at Building CUSTSILOS -

Emission unit 022000 - THIS UNIT CONSISTS OF THE NEW COAL HANDLING, STORAGE, ANDPROCESSING SOURCES.

Emission unit 022000 is associated with the following emission points (EP):63302, 63303, 63304, 63305, 63306, 63307, 63308, 63309, 66001, 66002Process: ASF is located at Building ASF -

Process: CLB is located at Building COALBH -

Process: CLR is located at Building COALRAW1 -

Process: PFS is located at Building PFSILO -

Emission unit 091000 - THIS UNIT CONSISTS OF THE PLANT ROADS AND PILES OUTSIDETHE QUARRY.

Process: ROD Fugitive particulate emissions.

Title V/Major Source StatusLAFARGE BUILDING MATERIALS INC is subject to Title V requirements. This determination is basedon the following information:

Program Applicability

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The following chart summarizes the applicability of LAFARGE BUILDING MATERIALS INC withregards to the principal air pollutionregulatory programs:

Regulatory Program Applicability------------------------------------------------------------------------------------------------------------------

PSD YES

NSR (non-attainment) NO

NESHAP (40 CFR Part 61) YES

NESHAP (MACT - 40 CFR Part 63) YES

NSPS YES

TITLE IV NO

TITLE V YES

TITLE VI NO

RACT YES

SIP YES

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NOTES:PSD Prevention of Significant Deterioration (40 CFR 52, 6 NYCRR 231-7, 231-8) -requirements which pertain to major stationary sources located in areas which are in attainment ofNational Ambient Air Quality Standards (NAAQS) for specified pollutants.

NSR New Source Review (6 NYCRR 231-5, 231-6) - requirements which pertain tomajor stationary sources located in areas which are in non-attainment of National Ambient AirQuality Standards (NAAQS) for specified pollutants.

NESHAP National Emission Standards for Hazardous Air Pollutants (40 CFR 61, 6 NYCRR 200.10) -contaminant and source specific emission standards established prior to the Clean Air Act Amendmentsof 1990 (CAAA) which were developed for 9 air contaminants (inorganic arsenic, radon, benzene,vinyl chloride, asbestos, mercury, beryllium, radionuclides, and volatile HAP's).

MACT Maximum Achievable Control Technology (40 CFR 63, 6 NYCRR 200.10) - contaminantand source specific emission standards established by the 1990 CAAA. Under Section 112 of the CAAA,the US EPA is required to develop and promulgate emissions standards for new and existing sources.The standards are to be based on the best demonstrated control technology and practices in the regulatedindustry, otherwise known as MACT. The corresponding regulations apply to specific source types andcontaminants.

NSPS New Source Performance Standards (40 CFR 60, 6 NYCRR 200.10) - standards ofperformance for specific stationary source categories developed by the US EPA under Section 111 ofthe CAAA. The standards apply only to those stationary sources which have been constructed or modifiedafter the regulations have been proposed by publication in the Federal Register and only to the specificcontaminant(s) listed in the regulation.

Title IV Acid Rain Control Program (40 CFR 72 thru 78, 6 NYCRR 201-6) - regulations whichmandate the implementation of the acid rain control program for large stationary combustion facilities.

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Title VI Stratospheric Ozone Protection (40 CFR 82, Subpart A thru G, 6 NYCRR 200.10) -federal requirements that apply to sources which use a minimum quantity of CFC’s (chlorofluorocarbons),HCFC’s (hydrofluorocarbons) or other ozone depleting substances or regulated substitute substances inequipment such as air conditioners, refrigeration equipment or motor vehicle air conditioners or appliances.

RACT Reasonably Available Control Technology (6 NYCRR Parts 212-3, 220-1.6, 220-1.7,220-2.3, 220-2.4, 226, 227-2, 228, 229, 230, 233, 234, 235, 236) - the lowest emission limit that aspecific source is capable of meeting by application of control technology that is reasonably available,considering technological and economic feasibility. RACT is a control strategy used to limitemissions of VOC’s and NOx for the purpose of attaining the air quality standard for ozone. Theterm as it is used in the above table refers to those state air pollution control regulations whichspecifically regulate VOC and NOx emissions.

SIP State Implementation Plan (40 CFR 52, Subpart HH, 6 NYCRR 200.10) - as per theCAAA, all states are empowered and required to devise the specific combination of controls that,when implemented, will bring about attainment of ambient air quality standards established by thefederal government and the individual state. This specific combination of measures is referred to asthe SIP. The term here refers to those state regulations that are approved to be included in the SIPand thus are considered federally enforceable.

Compliance StatusFacility is in compliance with all requirements.

SIC CodesSIC or Standard Industrial Classification code is an industrial code developed by the federal Office ofManagement and Budget for use, among other things, in the classification of establishments by the type ofactivity in which they are engaged. Each operating establishment is assigned an industry code on the basisof its primary activity, which is determined by its principal product or group of products produced ordistributed, or services rendered. Larger facilities typically have more than one SIC code.

SIC Code Description

3241 CEMENT, HYDRAULIC

SCC CodesSCC or Source Classification Code is a code developed and used'' by the USEPA to categorize processeswhich result in air emissions for the purpose of assessing emission factor information.Each SCC representsa unique process or function within a source category logically associated with a point of air pollutionemissions. Any operation that causes air pollution can be represented by one or more SCC’s.

SCC Code Description

3-05-006-06 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Kilns

3-05-006-10 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Secondary Crushing

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3-05-006-12 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Raw Material Transfer

3-05-006-14 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Clinker Cooler

3-05-006-16 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Clinker Transfer

3-05-006-17 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Clinker Grinding

3-05-006-18 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Cement Silos

3-05-006-99 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (DRYPROCESS)Other Not Classified

3-05-007-06 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Kilns

3-05-007-09 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Primary Crushing

3-05-007-10 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Secondary Crushing

3-05-007-12 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Raw Material Transfer

3-05-007-14 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Clinker Cooler

3-05-007-16 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Clinker Transfer

3-05-007-17 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Clinker Grinding

3-05-007-18 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)CEMENT SILOS

3-05-007-19 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Cement Load Out

3-05-007-29 MINERAL PRODUCTSMINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)FINISH GRINDING MILL AIR SEPARATOR

3-05-007-99 MINERAL PRODUCTS

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MINERAL PRODUCTS - CEMENT MANUFACTURE (WETPROCESS)Other Not Classified

3-05-025-04 MINERAL PRODUCTSMINERAL PRODUCTS - CONSTRUCTION SAND ANDGRAVELHauling

3-05-101-03 MINERAL PRODUCTSMINERAL PRODUCTS - BULK MATERIALS CONVEYORSCoal

3-05-102-03 MINERAL PRODUCTSMINERAL PRODUCTS - BULK MATERIALS STORAGEBINSCoal

3-05-102-99 MINERAL PRODUCTSMINERAL PRODUCTS - BULK MATERIALS STORAGEBINSOther Not Classified

Facility Emissions SummaryIn the following table, the CAS No. or Chemical Abstract Service code is an identifier assigned to everychemical compound. [NOTE: Certain CAS No.’s contain a ‘NY’ designation within them. These are nottrue CAS No.’s but rather an identification which has been developed by the department to identify groupsof contaminants which ordinary CAS No.’s do not do. As an example, volatile organic compounds orVOC’s are identified collectively by the NY CAS No. 0NY998-00-0.] The PTE refers to the Potential toEmit. This is defined as the maximum capacity of a facility or air contaminant source to emit any aircontaminant under its physical and operational design. Any physical or operational limitation on thecapacity of the facility or air contamination source to emit any air contaminant , including air pollutioncontrol equipment and/or restrictions on the hours of operation, or on the type or amount or materialcombusted, stored, or processed, shall be treated as part of the design only if the limitation is contained infederally enforceable permit conditions. The PTE for each contaminant that is displayed represents thefacility-wide PTE in tons per year (tpy) or pounds per year (lbs/yr). In some instances the PTE representsa federally enforceable emissions cap or limitation for that contaminant. The term ‘HAP’ refers to any ofthe hazardous air pollutants listed in section 112(b) of the Clean Air Act Amendments of 1990. Totalemissions of all hazardous air pollutants are listed under the special NY CAS No. 0NY100-00-0. Inaddition, each individual hazardous air pollutant is also listed under its own specific CAS No. and isidentified in the list below by the (HAP) designation.

Cas No. Contaminant PTE lbs/yr PTE tons/yr Actual lbs/yr Actual tons/yr000084-74-2 1,2-

BENZENEDICARBOXYLIC ACID,DIBUTYL ESTER

001746-01-6 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN

0NY504-00-0 40 CFR 63 -TOTALHYDROCARBONS (THC)

000075-07-0 ACETALDEHYDE000107-02-8 ACROLEIN007664-41-7 AMMONIA007440-36-0 ANTIMONY007440-38-2 ARSENIC007440-39-3 BARIUM

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000071-43-2 BENZENE007440-41-7 BERYLLIUM007440-43-9 CADMIUM000124-38-9 CARBON

DIOXIDE000075-15-0 CARBON

DISULFIDE000630-08-0 CARBON

MONOXIDE21620000

000108-90-7 CHLOROBENZENE

007440-47-3 CHROMIUM018540-29-9 CHROMIUM(VI)007440-48-4 COBALT007440-50-8 COPPER000075-09-2 DICHLOROMETH

ANE000100-41-4 ETHYLBENZENE000050-00-0 FORMALDEHYDE007647-01-0 HYDROGEN

CHLORIDE007664-39-3 HYDROGEN

FLUORIDE007439-92-1 LEAD007439-96-5 MANGANESE007439-97-6 MERCURY000074-82-8 METHANE000074-83-9 METHYL

BROMIDE000074-87-3 METHYL

CHLORIDE000091-20-3 NAPHTHALENE0NY059-28-0 NICKEL (NI 059)007440-02-0 NICKEL METAL

AND INSOLUBLECOMPOUNDS

0NY210-00-0 OXIDES OFNITROGEN

7500000

0NY075-00-0 PARTICULATES011096-82-5 PCB 1260000108-95-2 PHENOL0NY075-02-5 PM 2.50NY075-00-5 PM-10001336-36-3 POLYCHLORINA

TED BIPHENYL0NY505-00-0 POLYCYCLIC

ORGANICMATTER (POM)

007782-49-2 SELENIUM007440-22-4 SILVER000100-42-5 STYRENE007704-34-9 SULFUR007446-09-5 SULFUR DIOXIDE 14000000012624-32-7 SULFUR OXIDE007440-28-0 THALLIUM000108-88-3 TOLUENE0NY100-00-0 TOTAL HAP007440-62-2 VANADIUM000075-01-4 VINYL

CHLORIDE0NY998-00-0 VOC001330-20-7 XYLENE, M, O &

P MIXT.007440-66-6 ZINC

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NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

Item A: Public Access to Recordkeeping for Title V Facilities - 6 NYCRR 201-1.10(b) The Department will make available to the public any permit application, compliance plan, permit, and monitoring and compliance certification report pursuant to Section 503(e) of the Act, except for information entitled to confidential treatment pursuant to 6 NYCRR Part 616 - Public Access to records and Section 114(c) of the Act.

Item B: Timely Application for the Renewal of Title V Permits -6 NYCRR Part 201-6.2(a)(4)

Owners and/or operators of facilities having an issued Title V permit shall submit a complete application at least 180 days, but not more than eighteen months, prior to the date of permit expiration for permit renewal purposes.

Item C: Certification by a Responsible Official - 6 NYCRR Part 201-6.2(d)(12) Any application, form, report or compliance certification required to be submitted pursuant to the federally enforceable portions of this permit shall contain a certification of truth, accuracy and completeness by a responsible official.This certification shall state that based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.

Item D: Requirement to Comply With All Conditions - 6 NYCRR Part 201-6.4(a)(2) The permittee must comply with all conditions of the Title V facility permit. Any permit non-compliance constitutes a violation of the Act and is grounds for enforcement action; for permit termination, revocation and reissuance, or modification; or for denial of a permit renewal application.

Item E: Permit Revocation, Modification, Reopening, Reissuance or Termination, and Associated Information Submission Requirements - 6 NYCRR Part 201-6.4(a)(3) This permit may be modified, revoked, reopened and reissued, or terminated for cause. The filing of a request by the permittee for a permit modification, revocation and reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any permit condition.

Item F: Cessation or Reduction of Permitted Activity Not a Defense - 6 NYCRR 201-6.4(a)(5) It shall not be a defense for a permittee in an enforcement action to claim that a cessation or reduction in the permitted activity would have been necessary in order to maintain compliance with the conditions of this permit.

Item G: Property Rights - 6 NYCRR 201-6.4(a)(6) This permit does not convey any property rights of any sort or any exclusive privilege.

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Item H: Severability - 6 NYCRR Part 201-6.4(a)(9) If any provisions, parts or conditions of this permit are found to be invalid or are the subject of a challenge, the remainder of this permit shall continue to be valid.

Item I: Permit Shield - 6 NYCRR Part 201-6.4(g) All permittees granted a Title V facility permit shall be covered under the protection of a permit shield, except as provided under 6 NYCRR Subpart 201-6. Compliance with the conditions of the permit shall be deemed compliance with any applicable requirements as of the date of permit issuance, provided that such applicable requirements are included and are specifically identified in the permit, or the Department, in acting on the permit application or revision, determines in writing that other requirements specifically identified are not applicable to the major stationary source, and the permit includes the determination or a concise summary thereof. Nothing herein shall preclude the Department from revising or revoking the permit pursuant to 6 NYCRR Part 621 or from exercising its summary abatement authority. Nothing in this permit shall alter or affect the following:

i. The ability of the Department to seek to bring suit on behalf of the State ofNew York, or the Administrator to seek to bring suit on behalf of the UnitedStates, to immediately restrain any person causing or contributing to pollutionpresenting an imminent and substantial endangerment to public health, welfare orthe environment to stop the emission of air pollutants causing or contributing tosuch pollution;

ii. The liability of a permittee of the Title V facility for any violation ofapplicable requirements prior to or at the time of permit issuance;

iii. The applicable requirements of Title IV of the Act;

iv. The ability of the Department or the Administrator to obtain informationfrom the permittee concerning the ability to enter, inspect and monitor the facility.

Item J: Reopening for Cause - 6 NYCRR Part 201-6.4(i) This Title V permit shall be reopened and revised under any of the following circumstances:

i. If additional applicable requirements under the Act become applicable wherethis permit's remaining term is three or more years, a reopening shall becompleted not later than 18 months after promulgation of the applicablerequirement. No such reopening is required if the effective date of therequirement is later than the date on which this permit is due to expire, unlessthe original permit or any of its terms and conditions has been extended by theDepartment pursuant to the provisions of Part 2 01-6.7 and Part 621.

ii. The Department or the Administrator determines that the permit contains amaterial mistake or that inaccurate statements were made in establishing theemissions standards or other terms or conditions of the permit.

iii. The Department or the Administrator determines that the Title V permitmust be revised or reopened to assure compliance with applicable requirements.

iv. If the permitted facility is an "affected source" subject to the requirementsof Title IV of the Act, and additional requirements (including excess emissions

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requirements) become applicable. Upon approval by the Administrator, excessemissions offset plans shall be deemed to be incorporated into the permit.

Proceedings to reopen and issue Title V facility permits shall follow the sameprocedures as apply to initial permit issuance but shall affect only those parts ofthe permit for which cause to reopen exists. Reopenings shall not be initiated before a notice of such intent is provided tothe facility by the Department at least thirty days in advance of the date that thepermit is to be reopened, except that the Department may provide a shorter timeperiod in the case of an emergency.

Item K: Permit Exclusion - ECL 19-0305 The issuance of this permit by the Department and the receipt thereof by the Applicant does not and shall not be construed as barring, diminishing, adjudicating or in any way affecting any legal, administrative or equitable rights or claims, actions, suits, causes of action or demands whatsoever that the Department may have against the Applicant for violations based on facts and circumstances alleged to have occurred or existed prior to the effective date of this permit, including, but not limited to, any enforcement action authorized pursuant to the provisions of applicable federal law, the Environmental Conservation Law of the State of New York (ECL) and Chapter III of the Official Compilation of the Codes, Rules and Regulations of the State of New York (NYCRR). The issuance of this permit also shall not in any way affect pending or future enforcement actions under the Clean Air Act brought by the United States or any person.

Item L: Federally Enforceable Requirements - 40 CFR 70.6(b) All terms and conditions in this permit required by the Act or any applicable requirement, including any provisions designed to limit a facility's potential to emit, are enforceable by the Administrator and citizens under the Act. The Department has, in this permit, specifically designated any terms and conditions that are not required under the Act or under any of its applicable requirements as being enforceable under only state regulations.

NOTIFICATION OF GENERAL PERMITTEE OBLIGATIONS

Item A: Emergency Defense - 6 NYCRR 201-1.5

An emergency, as defined by subpart 201-2, constitutes an affirmative defense to penalties sought in an enforcement action brought by the Department for noncompliance with emissions limitations or permit conditions for all facilities in New York State.

(a) The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs, or other relevant evidence that:

(1) An emergency occurred and that the facility owner or operator can identify the cause(s) of the emergency;

(2) The equipment at the permitted facility causing the emergency was at the time being properly operated and maintained;

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(3) During the period of the emergency the facility owner or operator took all reasonable steps to minimize levels of emissions that exceeded the emission standards, or other requirements in the permit; and

(4) The facility owner or operator notified the Department within two working days after the event occurred. This notice must contain a description of the emergency, any steps taken to mitigate emissions, and corrective actions taken.

(b) In any enforcement proceeding, the facility owner or operator seeking to establish the occurrence of an emergency has the burden of proof.

(c) This provision is in addition to any emergency or upset provision contained in any applicable requirement. item_02

Item B: General Provisions for State Enforceable Permit Terms and Condition - 6 NYCRR Part 201-5 Any person who owns and/or operates stationary sources shall operate and maintain all emission units and any required emission control devices in compliance with all applicable Parts of this Chapter and existing laws, and shall operate the facility in accordance with all criteria, emission limits, terms, conditions, and standards in this permit. Failure of such person to properly operate and maintain the effectiveness of such emission units and emission control devices may be sufficient reason for the Department to revoke or deny a permit.

The owner or operator of the permitted facility must maintain all required records on-site for a period of five years and make them available to representatives of the Department upon request. Department representatives must be granted access to any facility regulated by this Subpart, during normal operating hours, for the purpose of determining compliance with this and any other state and federal air pollution control requirements, regulations or law.

Regulatory Analysis

Location Regulation Condition Short DescriptionFacility/EU/EP/Process/ES----------------------------------------------------------------------------------------------------------------------------------FACILITY ECL 19-0301 84 Powers and Duties of

the Department withrespect to airpollution control

0-41000/43101/K12 40CFR 52-A.21(r) 75 Source obligation0-41100/33401/KLN 40CFR 60-F.62(a)(3) 12 -70 Portland Cement

Plants - Standardsfor Nitrogen Oxide

0-41100/33401/KLN 40CFR 60-F.62(a)(4) 12 -71 NSPS for PortlandCement Plants -Sulfur DioxideStandards

FACILITY 40CFR 60-OOO.670(a) 12 -31 Rock, gravel, sand,and clay processingand conveying

FACILITY 40CFR 60-OOO.674(c) 12 -32 Rock, gravel, sand

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and clay processingand conveying -monitoring ofoperations

FACILITY 40CFR 60-Y.254(b) 12 -29, 12 -30 Standards ofPerformance for CoalPreparation Plants -standards

0-41000/43101/K12 40CFR 63-A.10(e)(3)(i)

77 Part 63 ReportingRequirements forExcess Emissions andContinuous MonitoringSystems

FACILITY 40CFR 63-A.6(i) 20 -22 Compliance DateExtension

FACILITY 40CFR 63-LLL.1341 12 -33 Portland CementNESHAP - Definitions

FACILITY 40CFR 63-LLL.1342 47 NESHAP for PortlandCement Manufacturing- General Standards

0-41000 40CFR 63-LLL.1342 63 NESHAP for PortlandCement Manufacturing- General Standards

FACILITY 40CFR 63-LLL.1343(b)(1)

20 -23, 20 -24 NESHAP for PortlandCement Manufacturing- Standards for kilnsand in-line kilns/rawmills

0-41000/43101/K12 40CFR 63-LLL.1343(b)(1)

20 -47, 20 -48, 20 -49, 20 -50

NESHAP for PortlandCement Manufacturing- Standards for kilnsand in-line kilns/rawmills

0-41000/45101/K12 40CFR 63-LLL.1343(b)(1)

20 -51 NESHAP for PortlandCement Manufacturing- Standards for kilnsand in-line kilns/rawmills

0-41100/33401 40CFR 63-LLL.1343(b)(1)


0-41100/33401/CCL 40CFR 63-LLL.1343(b)(1)


0-41100/33401/KLN 40CFR 63-LLL.1343(b)(1)

12 -73, 12 -74, 20 -54, 20 -55, 20 -56

NESHAP for PortlandCement Manufacturing- Standards for kilnsand in-line kilns/rawmills

0-41000/43101/K12 40CFR 63-LLL.1343(b)(3)

12 -61 Existing,reconstructed or newbrownfield/majorsources

FACILITY 40CFR 63-LLL.1343(d) 20 -25, 20 -26, 20 -27, 20 -28

Portland CementNESHAP - Standardsfor PM, mercury, THC,D/F at existingsources - Table 2 ofSubpart LLL

FACILITY 40CFR 63-LLL.1343(e) 12 -35, 12 -36, 12 -37, 12 -38

Portland CementNESHAP - Emission

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limitsFACILITY 40CFR 63-LLL.1346 20 -29 NESHAP for Portland

Cement Manufacturing- Standards for newor reconstructed rawmaterial dryers

FACILITY 40CFR 63-LLL.1346(g) 20 -30 Portland CementNESHAP -startup/shutdownprovisions

FACILITY 40CFR 63-LLL.1347 20 -31 NESHAP for PortlandCement Manufacturing- Operation andMaintenance PlanRequirements


20 -32 ComplianceRequirements -Startup and Shutdown


20 -33 Portland CementNESHAP - PMMonitoringRequirements

FACILITY 40CFR 63-LLL.1350(f) 12 -41, 12 -43, 20 -34

Monitoringrequirements

0-20000 40CFR 63-LLL.1350(f) 20 -36 Monitoringrequirements

0-41000/-/K12 40CFR 63-LLL.1350(g) 20 -38 Portland CementNESHAP - D/FMonitoringRequirements

FACILITY 40CFR 63-LLL.1353 12 -45 NotificationRequirements

FACILITY 40CFR 63-LLL.1355 20 -35 RecordkeepingRequirements

FACILITY 40CFR 68 20 Chemical accidentprevention provisions

FACILITY 40CFR 82-F 21 Protection ofStratospheric Ozone -recycling andemissions reduction

FACILITY 6NYCRR 200.6 1 Acceptable ambientair quality.

FACILITY 6NYCRR 200.7 9, 22 Maintenance ofequipment.

FACILITY 6NYCRR 201-1.4 85, 20 -60 Unavoidablenoncompliance andviolations

FACILITY 6NYCRR 201-1.7 20 -6 Recycling and SalvageFACILITY 6NYCRR 201-1.8 11 Prohibition of

reintroduction ofcollectedcontaminants to theair

FACILITY 6NYCRR 201-3.2(a) 20 -7 Exempt Activities -Proof of eligibility

FACILITY 6NYCRR 201-3.3(a) 20 -8 Trivial Activities -proof of eligibility

FACILITY 6NYCRR 201-6 23, 60, 61 Title V Permits andthe Associated PermitConditions

FACILITY 6NYCRR 201-6.4(a)(4) 20 -9 General Conditions -Requirement toProvide Information

FACILITY 6NYCRR 201-6.4(a)(7) 20 -1 General Conditions -Fees

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FACILITY 6NYCRR 201-6.4(a)(8) 20 -10 General Conditions -Right to Inspect

FACILITY 6NYCRR 201-6.4(c) 20 -2 Recordkeeping andReporting ofCompliance Monitoring

FACILITY 6NYCRR 201-6.4(c)(2) 20 -3 Records ofMonitoring, Samplingand Measurement

FACILITY 6NYCRR 201-6.4(c)(3)(ii

20 -4 ReportingRequirements -Deviations andNoncompliance

FACILITY 6NYCRR 201-6.4(d)(4) 20 -12 Compliance Schedules- Progress Reports

FACILITY 6NYCRR 201-6.4(e) 20 -5 ComplianceCertification

FACILITY 6NYCRR 201-6.4(f) 20 -13 OperationalFlexibility

FACILITY 6NYCRR 201-6.4(f)(6) 20 -11 Off Permit ChangesFACILITY 6NYCRR 201-6.5(e) 25 Compliance

CertificationFACILITY 6NYCRR 201-7 12 -47, 20 -14 Federally Enforceable

Emissions CapsFACILITY 6NYCRR 202-1.1 18, 20 -15, 20 -16 Required emissions

tests.FACILITY 6NYCRR 202-1.2 28 Notification.FACILITY 6NYCRR 202-1.3(a) 29 Acceptable procedures

- reference methodsFACILITY 6NYCRR 202-2.1 6 Emission Statements -

ApplicabilityFACILITY 6NYCRR 202-2.5 7 Emission Statements -

record keepingrequirements.

FACILITY 6NYCRR 211.1 12 -8, 12 -9 General Prohibitions- air pollutionprohibited

FACILITY 6NYCRR 211.2 12 -79 General Prohibitions- visible emissionslimited.

FACILITY 6NYCRR 212.3(b) 30 General ProcessEmission Sources -emissions fromexisting emissionsources

FACILITY 6NYCRR 212.4(c) 31 General ProcessEmission Sources -emissions from newprocesses and/ormodifications

FACILITY 6NYCRR 212.6(a) 32 General ProcessEmission Sources -opacity of emissionslimited

FACILITY 6NYCRR 212.9 20 -61, 20 -62 Tables.FACILITY 6NYCRR 215.2 8 Open Fires -

Prohibitions0-41000 6NYCRR 220-1.2(b) 20 -37 Particulate emission

limit for largeexisting kilns andclinker coolers.

0-41000/43101/K12 6NYCRR 220-1.4(a) 20 -44 Opacity limits forportland cementprocesses.

FACILITY 6NYCRR 220-1.4(c) 20 -17 Opacity limits forportland cement

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processes.0-42000 6NYCRR 220-1.5(a) 20 -57 Particulate emissions

from dust dumps.0-42000 6NYCRR 220-1.5(b) 20 -58 Particulate emissions

from dust dumps.0-42000 6NYCRR 220-1.5(c) 20 -59 Particulate emissions

from dust dumps.0-41000/43101/K12 6NYCRR 220-1.6(a) 20 -45 Sulfur dioxide

emissions from kilnstacks.

FACILITY 6NYCRR 220-1.6(b)(1) 20 -18 Emission of nitrogenoxides from kilnstacks - existingkiln RACT dates.

0-41000/43101/K12 6NYCRR 220-1.7(a) 20 -46 Kiln and clinkercooler recordkeeping.

FACILITY 6NYCRR 225-1.2 20 -19, 20 -20, 20 -21

Sulfur-in-FuelLimitations

FACILITY 6NYCRR 225-1.2(d) 12 -10 Sulfur-in-fuellimitations - Table 2

FACILITY 6NYCRR 231-8 12 -14, 12 -16, 12 -17

Mods to ExistingMajor Facilities inAttainment Areas(PSD)

0-41100 6NYCRR 231-8 12 -66 Mods to ExistingMajor Facilities inAttainment Areas(PSD)

0-41100/-/KLN 6NYCRR 231-8 20 -52 Mods to ExistingMajor Facilities inAttainment Areas(PSD)

FACILITY 6NYCRR 243-1.6(a) 12 -18 Permit Requirements -CAIR NOx Ozone SeasonTrading Program

FACILITY 6NYCRR 243-1.6(b) 12 -19 MonitoringRequirements - CAIRNOx Ozone SeasonTrading Program

FACILITY 6NYCRR 243-1.6(c) 12 -20 NOx Ozone SeasonEmission Requirements- CAIR NOx OzoneSeason TradingProgram

FACILITY 6NYCRR 243-1.6(d) 12 -21 Excess EmissionRequirements - CAIRNOx Ozone SeasonTrading Program

FACILITY 6NYCRR 243-1.6(e) 12 -22 Recordkeeping andreportingrequirements - CAIRNOx Ozone SeasonTrading Program

FACILITY 6NYCRR 243-2.1 12 -23 Authorization andresponsibilities -CAIR DesignatedRepresentative

FACILITY 6NYCRR 243-2.4 12 -24 Certificate ofrepresentation - CAIRDesignatedRepresentative

FACILITY 6NYCRR 243-8.1 12 -25, 12 -26 General Requirements- Monitoring andReporting

FACILITY 6NYCRR 243-8.5(d) 12 -27 Quarterly reports re:

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recordkeeping andreporting -Monitoring andReporting

FACILITY 6NYCRR 243-8.5(e) 12 -28 Compliancecertification re:recordkeeping andreporting -Monitoring andReporting

Applicability Discussion:Mandatory Requirements: The following facility-wide regulations are included in all Title V permits:

ECL 19-0301This section of the Environmental Conservation Law establishes the powers and duties assigned to theDepartment with regard to administering the air pollution control program for New York State.

6 NYCRR 200.6Acceptable ambient air quality - prohibits contravention of ambient air quality standards without mitigatingmeasures

6 NYCRR 200.7Anyone owning or operating an air contamination source which is equipped with an emission controldevice must operate the control consistent with ordinary and necessary practices, standards andprocedures, as per manufacturer's specifications and keep it in a satisfactory state of maintenance andrepair so that it operates effectively

6 NYCRR 201-1.4This regulation specifies the actions and recordkeeping and reporting requirements for any violation of anapplicable state enforceable emission standard that results from a necessary scheduled equipmentmaintenance, start-up, shutdown, malfunction or upset in the event that these are unavoidable.

6 NYCRR 201-1.7Requires the recycle and salvage of collected air contaminants where practical

6 NYCRR 201-1.8Prohibits the reintroduction of collected air contaminants to the outside air

6 NYCRR 201-3.2 (a)An owner and/or operator of an exempt emission source or unit may be required to certify that it operateswithin the specific criteria described in this Subpart. All required records must be maintained on-site for aperiod of 5 years and made available to department representatives upon request. In addition, departmentrepresentatives must be granted access to any facility which contains exempt emission sources or units,during normal operating hours, for the purpose of determining compliance with this and any other state andfederal air pollution control requirements, regulations, or law.

6 NYCRR 201-3.3 (a)The owner and/or operator of a trivial emission source or unit may be required to certify that it operateswithin the specific criteria described in this Subpart. All required records must be maintained on-site for aperiod of 5 years and made available to department representatives upon request. In addition, departmentrepresentatives must be granted access to any facility which contains trivial emission sources or unitssubject to this Subpart, during normal operating hours, for the purpose of determining compliance with this

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and any other state and federal air pollution control requirements, regulations, or law.

6 NYCRR Subpart 201-6This regulation applies to those terms and conditions which are subject to Title V permitting. It establishesthe applicability criteria for Title V permits, the information to be included in all Title V permitapplications as well as the permit content and terms of permit issuance. This rule also specifies thecompliance, monitoring, recordkeeping, reporting, fee, and procedural requirements that need to be met toobtain a Title V permit, modify the permit and demonstrate conformity with applicable requirements aslisted in the Title V permit. For permitting purposes, this rule specifies the need to identify and describe allemission units, processes and products in the permit application as well as providing the Department theauthority to include this and any other information that it deems necessary to determine the compliancestatus of the facility.

6 NYCRR 201-6.4 (a) (4)This mandatory requirement applies to all Title V facilities. It requires the permittee to provideinformation that the Department may request in writing, within a reasonable time, in order to determinewhether cause exists for modifying, revoking and reissuing, or terminating the permit or to determinecompliance with the permit. The request may include copies of records required to be kept by the permit.

6 NYCRR 201-6.4 (a) (7) This is a mandatory condition that requires the owner or operator of a facility subject to Title Vrequirements to pay all applicable fees associated with the emissions from their facility.

6 NYCRR 201-6.4 (a) (8)This is a mandatory condition for all facilities subject to Title V requirements. It allows the Department toinspect the facility to determine compliance with this permit, including copying records, sampling andmonitoring, as necessary.

6 NYCRR 201-6.4 (c)This requirement specifies, in general terms, what information must be contained in any requiredcompliance monitoring records and reports. This includes the date, time and place of any sampling,measurements and analyses; who performed the analyses; analytical techniques and methods used as wellas any required QA/QC procedures; results of the analyses; the operating conditions at the time ofsampling or measurement and the identification of any permit deviations. All such reports must also becertified by the designated responsible official of the facility.

6 NYCRR 201-6.4 (c) (2)This requirement specifies that all compliance monitoring and recordkeeping is to be conducted accordingto the terms and conditions of the permit and follow all QA requirements found in applicable regulations.It also requires monitoring records and supporting information to be retained for at least 5 years from thetime of sampling, measurement, report or application. Support information is defined as including allcalibration and maintenance records and all original strip-chart recordings for continuous monitoringinstrumentation, and copies of all reports required by the permit.

6 NYCRR 201-6.4 (c) (3) (ii)This regulation specifies any reporting requirements incorporated into the permit must include provisionsregarding the notification and reporting of permit deviations and incidences of noncompliance stating theprobable cause of such deviations, and any corrective actions or preventive measures taken.

6 NYCRR 201-6.4 (d) (4)This condition applies to every Title V facility subject to a compliance schedule. It requires that reports,

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detailing the status of progress on achieving compliance with emission standards, be submittedsemiannually.

6 NYCRR 201-6.4 (e)Sets forth the general requirements for compliance certification content; specifies an annual submittalfrequency; and identifies the EPA and appropriate regional office address where the reports are to be sent.

6 NYCRR 201-6.4 (f) (6)This condition allows changes to be made at the facility, without modifying the permit, provided thechanges do not cause an emission limit contained in this permit to be exceeded. The owner or operator ofthe facility must notify the Department of the change. It is applicable to all Title V permits which may besubject to an off permit change.

6 NYCRR 201-6.4 (e)Sets forth the general requirements for compliance certification content; specifies an annual submittalfrequency; and identifies the EPA and appropriate regional office address where the reports are to be sent.

6 NYCRR 202-1.1This regulation allows the department the discretion to require an emission test for the purpose ofdetermining compliance. Furthermore, the cost of the test, including the preparation of the report are to beborne by the owner/operator of the source.

6 NYCRR 202-2.1Requires that emission statements shall be submitted on or before April 15th each year for emissions of theprevious calENDar year.

6 NYCRR 202-2.5This rule specifies that each facility required to submit an emission statement must retain a copy of thestatement and supporting documentation for at least 5 years and must make the information available todepartment representatives.

6 NYCRR 211.2This regulation limits opacity from sources to less than or equal to 20 percent (six minute average) exceptfor one continuous six-minute period per hour of not more than 57 percent opacity.

6 NYCRR 215.2Except as allowed by section 215.3 of 6 NYCRR Part 215, no person shall burn, cause, suffer, allow orpermit the burning of any materials in an open fire.

40 CFR Part 68This Part lists the regulated substances and there applicability thresholds and sets the requirements forstationary sources concerning the prevention of accidental releases of these substances.

40 CFR Part 82, Subpart FSubpart F requires the reduction of emissions of class I and class II refrigerants to the lowest achievablelevel during the service, maintenance, repair, and disposal of appliances in accordance with section 608 ofthe Clean Air Act AmENDments of 1990. This subpart applies to any person servicing, maintaining, orrepairing appliances except for motor vehicle air conditioners. It also applies to persons disposing ofappliances, including motor vehicle air conditioners, refrigerant reclaimers, appliance owners, andmanufacturers of appliances and recycling and recovery equipment. Those individuals, operations, oractivities affected by this rule, may be required to comply with specified disposal, recycling, or recovery

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practices, leak repair practices, recordkeeping and/or technician certification requirements.

Facility Specific RequirementsIn addition to Title V, LAFARGE BUILDING MATERIALS INC has been determined to be subject to thefollowing regulations:40 CFR 52.21 (r)Source Obligation:

40 CFR 60.254 (b)Opacity and PM emission limits for coal conveying, transfer and storage systems.

40 CFR 60.62 (a) (3)NOx emission limit for new kilns. Related monitoring recordkeeping and reporting provisions of 40 CFRPart 60, Subpart F are also applicable.

40 CFR 60.62 (a) (4)SO2 emission limit for new kiln.

40 CFR 60.670 (a)PM and opacity emission limits for new nonmetalic mineral transfer and storage facilities.

40 CFR 60.674 (c)This regulation requires quarterly opacity monitoring for non-metallic mineralprocessing units that use a baghouse to control particulates.

40 CFR 63.10 (e) (3) (i)These are general conditions that apply to facilities subject to a NESHAP.

40 CFR 63.1341

.

40 CFR 63.1342This section provides general emission standards and operating limits for specific sources at PortlandCement Manufacturing Facilities. Table 1 provides a summary.

40 CFR 63.1343 (b) (1)This section provides particulate matter emission limitations for certain operations (kilns and in-linekiln/raw mills) at existing, reconstructed, or new brownfield/major sources.

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40 CFR 63.1343 (b) (3)Contained here are Dioxin/Furan emission limits for certain operations (kilns and in-line kiln/raw mills)at existing, reconstructed, or new brownfield/major sources.

40 CFR 63.1343 (d)

40 CFR 63.1343 (e)PM, opacity, D/F, and THC limits for existing kilns and coolers.

40 CFR 63.1346

40 CFR 63.1346 (g)

40 CFR 63.1347

40 CFR 63.1348 (b) (9)

40 CFR 63.1350 (b) (1)

40 CFR 63.1350 (f)The owner or operator of an affected source shall monitor D/F emissions by continuously monitoring andrecording the exhaust gas temperature from various devices. The temperature monitor shall be calibratedand maintained to ensure accurate readings. Dioxins and furans (D/F) means tetra-, penta-, hexa-, hepta-,and octa- chlorinated dibenzo dioxins.

40 CFR 63.1350 (g)

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40 CFR 63.1353Notification requirements including performance tests, visible emission observations, and compliancestatus, among other things, are specified in this section.

40 CFR 63.1355Recordkeeping requirements specify that the owner or operator shall maintain files of all requiredinformation on site for inspection and review purposes. Generally, the files are kept for a minimum offive years.

40 CFR 63.6 (i)

6 NYCRR 201-6.4 (f)This section describes the operational flexibility protocol proposed by the facility. Theprotocol will allow the facility owner or operator to make certain changes at the facilitywithout the need for a permit modification. Changes made pursuant to the protocol mustbe approved by the Department, and will be rolled into the permit during the nextrenewal or modification.

6 NYCRR 202-1.2This regulation specifies that the department is to be notified at least 30 days in advance of any requiredstack test. The notification is to include a list of the procedures to be used that are acceptable to thedepartment. Finally, free access to observe the stack test is to be provided to the department'srepresentative.

6 NYCRR 202-1.3 (a)This regulation requires that any emission testing, sampling and analytical determination used todetermine compliance must use methods acceptable to the department. Acceptable test methods mayinclude but are not limited to the reference methods found in 40 CFR Part 60 appendix A and Part 61,appendix B. In addition, unless otherwise specified, all emission test reports must be submitted within60 days after completion of testing.

6 NYCRR 211.1.

6 NYCRR 212.3 (b)This rule requires existing sources (in operation on or before July 1, 1973) of solid particulates withenvironmental rating of B or C which are not subject to Table 5 "Processes for which PermissibleEmission Rate is Based on Process Weight, to be limited to an particulate emission rate not to exceed0.15 grains per dry standard cubic foot.

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6 NYCRR 212.4 (c)This rule requires existing sources (in operation after July 1, 1973) of solid particulates withenvironmental rating of B or C which are not subject to Table 5 "Processes for which PermissibleEmission Rate is Based on Process Weight, to be limited to an particulate emission rate not to exceed0.05 grains per dry standard cubic foot.

6 NYCRR 212.6 (a)This rule specifies an opacity limitation of less than 20% for any six consecutive minute period for allprocess emission sources.

6 NYCRR 212.9This section of the regulation contains the descriptions and definitions of the environmental ratingssystem and the tables which set the emission standards for each rating.

6 NYCRR 220-1.2 (b)

6 NYCRR 220-1.4 (a)

6 NYCRR 220-1.4 (c)

6 NYCRR 220-1.5 (a)

6 NYCRR 220-1.5 (b)

6 NYCRR 220-1.5 (c)

6 NYCRR 220-1.6 (a)

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6 NYCRR 220-1.6 (b) (1)

6 NYCRR 220-1.7 (a)

6 NYCRR 225-1.2This section of the regulation establishes sulfur-in-fuel limitations for coal, residual oil,distillate oil, and waste oil.

6 NYCRR 225-1.2 (d)The sulfur-in-fuel limitations for residual and distillate oil and for solid fuel are listed in Tables 1,2 and 3or 6 NYCRR Part 225-1.2(c), (d) and (e)

6 NYCRR 243-1.6 (a)This condition requires the facility to acknowledge that they are subject to this CAIR regulation andprovide owner and contact information. It also requires them to update this information as it changes orprovide supplemental information at the Departments request.

6 NYCRR 243-1.6 (b)This condition obligates the owners and operators of the facility to comply with the monitoring andreporting requirements of the CAIR regulations.

6 NYCRR 243-1.6 (c)This citation explains the general provisions of the Clean Air Interstate Rule (CAIR) NOx Ozone SeasonTrading Program. This ozone season NOx cap and trade program runs from May 1 through September30 each year, starting in 2009. Each source shall hold a tonnage equivalent in CAIR NOx Ozone Seasonallowances that is not less than the total tons of NOx emissions for the ozone season.

6 NYCRR 243-1.6 (d)This citation for the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program explainssome of the penalties that can be imposed on a CAIR NOx Ozone Season source that does not surrenderenough CAIR NOx Ozone Season allowances to cover their NOx Ozone Season emissions.

6 NYCRR 243-1.6 (e)This citation for the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program requires thatall reports be submitted as required by this program, and that copies of all records and submissions made

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for this program be kept on site for at least five years.

6 NYCRR 243-2.1This citation of the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program explains thatan CAIR NOx Ozone Season designated representative must be selected to submit, sign and certify eachsubmission on behalf of the source for the this program.

6 NYCRR 243-2.4This condition describes the required elements of the "Certificate of Representation" for the CAIRprogram and the certifying language required with submissions to the Department.

6 NYCRR 243-8.1This citation of the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program explains thatCAIR NOx Ozone Season Trading Program sources must install, certify and operate monitoring systemsthe meet the monitoring, recordkeeping, and reporting requirements in Subpart 6 NYCRR 243-8 and inSubpart H of 40 CFR Part 75.

6 NYCRR 243-8.5 (d)This citation of the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program explainswhat requirements the quarterly reports must meet.

6 NYCRR 243-8.5 (e)This citation of the Clean Air Interstate Rule (CAIR) NOx Ozone Season Trading Program explains thecompliance certification requirements the source must follow for each quarterly report.

6 NYCRR Subpart 201-7This regulation sets forth an emission cap that cannot be exceeded by the facility.

6 NYCRR Subpart 231-8

This subpart applies to modifications to existing major facilities in attainment areas(prevention of significant deterioration (PSD)).

Compliance CertificationSummary of monitoring activities at LAFARGE BUILDING MATERIALS INC:

Location Cond No. Type of MonitoringFacility/EU/EP/Process/ES

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0-41000/43101/K12 75 record keeping/maintenance procedures0-41100/33401/KLN 12-70 continuous emission monitoring (cem)0-41100/33401/KLN 12-71 continuous emission monitoring (cem)FACILITY 12-31 intermittent emission testingFACILITY 12-32 monitoring of process or control device parameters

as surrogateFACILITY 12-29 monitoring of process or control device parameters

as surrogateFACILITY 12-30 intermittent emission testing0-41000/43101/K12 77 record keeping/maintenance proceduresFACILITY 20-22 record keeping/maintenance proceduresFACILITY 20-23 record keeping/maintenance proceduresFACILITY 20-24 intermittent emission testing0-41000/43101/K12 20-47 continuous emission monitoring (cem)0-41000/43101/K12 20-48 continuous emission monitoring (cem)0-41000/43101/K12 20-49 continuous emission monitoring (cem)0-41000/43101/K12 20-50 continuous emission monitoring (cem)0-41000/45101/K12 20-51 intermittent emission testing0-41100/33401 12-67 continuous emission monitoring (cem)0-41100/33401/CCL 20-53 intermittent emission testing0-41100/33401/KLN 20-54 continuous emission monitoring (cem)0-41100/33401/KLN 20-55 continuous emission monitoring (cem)0-41100/33401/KLN 20-56 continuous emission monitoring (cem)0-41100/33401/KLN 12-73 continuous emission monitoring (cem)0-41100/33401/KLN 12-74 continuous emission monitoring (cem)0-41000/43101/K12 12-61 intermittent emission testingFACILITY 20-25 monitoring of process or control device parameters


as surrogateFACILITY 20-27 intermittent emission testingFACILITY 20-28 intermittent emission testingFACILITY 12-35 monitoring of process or control device parameters

as surrogateFACILITY 12-36 intermittent emission testingFACILITY 12-37 monitoring of process or control device parameters

as surrogateFACILITY 12-38 intermittent emission testingFACILITY 20-29 record keeping/maintenance proceduresFACILITY 20-30 record keeping/maintenance proceduresFACILITY 20-31 record keeping/maintenance proceduresFACILITY 20-32 record keeping/maintenance proceduresFACILITY 20-33 record keeping/maintenance proceduresFACILITY 20-34 monitoring of process or control device parameters


as surrogateFACILITY 12-43 continuous emission monitoring (cem)0-20000 20-36 record keeping/maintenance procedures0-41000/-/K12 20-38 record keeping/maintenance proceduresFACILITY 22 record keeping/maintenance proceduresFACILITY 20-4 record keeping/maintenance proceduresFACILITY 20-5 record keeping/maintenance proceduresFACILITY 20-13 record keeping/maintenance proceduresFACILITY 25 record keeping/maintenance proceduresFACILITY 12-4 intermittent emission testingFACILITY 12-5 intermittent emission testing0-41000/43101/K12 20-39 continuous emission monitoring (cem)0-41000/43101/K12 20-40 continuous emission monitoring (cem)0-41000/43101/K12 20-41 continuous emission monitoring (cem)0-41000/43101/K12 20-42 continuous emission monitoring (cem)

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0-41000/43101/K12 20-43 continuous emission monitoring (cem)0-41100 12-64 continuous emission monitoring (cem)0-41100 12-65 intermittent emission testingFACILITY 20-15 record keeping/maintenance proceduresFACILITY 20-16 record keeping/maintenance proceduresFACILITY 6 record keeping/maintenance proceduresFACILITY 12-9 record keeping/maintenance proceduresFACILITY 30 monitoring of process or control device parameters

as surrogateFACILITY 31 monitoring of process or control device parameters

as surrogateFACILITY 32 record keeping/maintenance proceduresFACILITY 20-61 monitoring of process or control device parameters


as surrogate0-41000 20-37 intermittent emission testing0-41000/43101/K12 20-44 continuous emission monitoring (cem)FACILITY 20-17 record keeping/maintenance procedures0-41000/43101/K12 20-45 record keeping/maintenance proceduresFACILITY 20-18 continuous emission monitoring (cem)0-41000/43101/K12 20-46 record keeping/maintenance proceduresFACILITY 20-19 work practice involving specific operationsFACILITY 20-20 work practice involving specific operationsFACILITY 20-21 work practice involving specific operationsFACILITY 12-10 work practice involving specific operationsFACILITY 12-16 work practice involving specific operationsFACILITY 12-17 work practice involving specific operations0-41100 12-66 continuous emission monitoring (cem)0-41100/-/KLN 20-52 continuous emission monitoring (cem)

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Basis for MonitoringFacility needs to monitor as per conditions outlined in the Title V permit.

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new york state department of environmental conservation ...permit id: 4-0124-00001/00112 renewal...

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